Insights
1,4-Dioxane: Occupational Exposure Considerations
Oct 18, 2022Summary
Workers may be exposed, and ultimately injured, by exposure to 1,4-dioxane. The principal pathway of exposure, as discussed below, is through inhalation. A worker’s level of exposure relates to the type of work being conducted, airborne concentrations of 1,4-dioxane, and the duration of exposure.
Examples of potential worker exposure to 1,4-dioxane include the following industries and situations:
- Researchers in scientific laboratories;
- Employees working with certain industrial solvents;
- Factory workers manufacturing certain cosmetics; and
- Workers in paper pulping industries.
Our firm had provided some background regarding 1,4-dioxane in a previous Client Alert. Importantly, 1,4-dioxane is of increasing interest to government agencies.
This Client Alert discusses federal and state occupational exposure standards addressing 1,4-dioxane.
I. Federal Requirements and Recommendations
The Occupational Health and Safety Administration (OSHA) governs worker safety, including exposure to 1,4-dioxane. OSHA established a research organization called the National Institute for Occupational Safety and Health (NIOSH), which created the occupational exposure standard for 1,4-dioxane. NIOSH and OSHA published an additional document that also discusses workplace exposure to 1,4-dioxane. As a note, NIOSH’s current guidance contains more protective levels than does OSHA’s enforceable levels.
The following table summarizes the requirements and recommendations for occupational exposure inhalation to 1,4-dioxane:
National Standards for 1,4-Dioxane Inhalation Exposure |
||
Agency/Organization |
Requirement |
Category |
OSHA |
100 parts per million (ppm) averaged over an 8-hour shift1 Airborne Permissible Exposure Limit |
Regulatory |
NIOSH |
1 ppm averaged over 30 minutes Airborne Exposure Limit |
Advisory |
American Conference of Government Industrial Hygienists (ACGIH) |
20 ppm averaged over an 8-hour shift Airborne Exposure Limit |
Advisory |
There are several documents available that, in part, discuss occupational safety regarding 1,4-dioxane:
- NIOSH’s Pocket Guide to Chemical Hazards;
- OSHA’s Chemical Database;
- EPA’s 1,4-dioxane Document;
- EPA’s Technical Fact Sheet;
- EPA’s Scope of the Risk Evaluation (expand the document using the lower left-hand corner);
- EPA’s Final Risk Evaluation (December 2020), but numerous state entities have challenged the findings in court (March 2021); and
- ACGIH’s Informational Sheet.
II. State Requirements and Recommendations
Many states have issued regulations or guidance to protect workers potentially exposed to 1,4-dioxane. California OSHA has established a Permissible Exposure Limit for 1,4-dioxane of 0.28 ppm averaged over an eight hour shift (or, approximately one-third of OSHA’s exposure limit, making California’s standard more stringent).
The following are the relevant information sheets published by the states:
- California (CA Office of Environmental Health Human Assessment);
- Connecticut (CT Department of Energy and Environmental Protection);
- Florida (FL Department of Health);
- Massachusetts (MA Department of Environmental Protection);
- Michigan (MI Department of Health and Human Services);
- New Hampshire (NH Department of Environmental Services);
- New Jersey (NJ Department of Health and Human Services);
- New York (NY Human Health Fact Sheet);
- North Carolina – Cape Fear River Basin (NC Environmental Quality);
- Vermont (VT Department of Health); and
- Wisconsin (WI Department of Health Services).
Several other states, cities, and counties have published information to address 1,4-dioxane in drinking water supplies. Minnesota Department of Health provides a helpful example.
III. Conclusion
We anticipate that regulation of occupational safety concerns for 1,4-dioxane at the federal and state levels will continue in the future. If you have any questions regarding 1,4-dioxane, please contact Phil Karmel (212-541-2311), John Kindschuh (314-259-2313), or Erin Brooks (314-259-2393).
1OSHA also states that 1,4-dioxane may be absorbed through the skin.
Related Practice Areas
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PFAS Team
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Environment